103 (1) Where the members of a partnership have agreed to share, in a specified propor
tion, any income or loss of the partnership from any source or from sources in a particular place, as the case may be, or any other amount in respect of any activity of the partnership that is relevant to the computation of the income or taxable income of any of the members thereof, and the princ
ipal reason for the agreement may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable un
...[+++]der this Act, the share of each member of the partnership in the income or loss, as the case may be, or in that other amount, is the amount that is reasonable having regard to all the circumstances including the proportions in which the members have agreed to share profits and losses of the partnership from other sources or from sources in other places.